i i *i water · 1; i impact of the proposed chunge. . wastewater discharge from the proposed wwtp...
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Dr. Karen Creed . , ulsce tireann Bosca OP 6000 Environmental Licencing Programme Eatie Atha dtath 1
Office of Climate, Licencing and Resource Use I tire
Irish Water PO Box 6000 Dublin 1
Environmental Protection Agency . _I * I
. I PO Box 3000
Wexford I *
Johnstown Castle Estate ; Ireland- 7
1: +353 1 89 25000 F +353 1 89 25W)l wmv.watcr.ie .
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< , . 28th February 2017.
IW-ER-LT0327 : *
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RE Youghal Waste Water Discharge Ucence : Techkcal Amendment Applkation
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DO13941 :* 4 t. > .
The Agency issued a Wastewater Discharge Licence for the Youghal bgglomeration (D0139- 01) on the 13'h June 2012. Irish Water now requests a Technical Amendment under Section 33 (1) of the Waste Water Discharge (Authorisation) Regulations 2007, as amended, to alter
,Discharges to be discontinued, A.$ Storm Water Overflows, Schedule B- and Schedule C.1 - - = - - Schedule--A1 Primary Waste Water Discharge, 'A.2 'Secondary Waste Water Discharge,-A:3 ---'-- .
* lmprovemen t Programme for Primary Discharge? " i
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,: ' Irish Water has had regard to the EPA's publication €PA Guidance for /fish voter on Fequests for Akeratiois to a Waste Water Discharge Licence or Certificate of Authork,&on in compiling this submission for a Technical Amendment
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Currently there is no wastewater treatment plant servicing the Youghal agglomeration and ./
wastewater is discharged to the lower Blackwater Estuary via three main outfalls (SWOOO, J
SW002 and SW003). A new wastewater treatment plant is due to be commissioned and?. operational by the 30th November 2017. The construction of the proposed primary discharge
~ outfall at 210852E, 078125N (SWOOl) has been delayed due to legal issues. Irish Water is 5 therefor applying to the Agency to seek authorisation for the discharge of treated wastewater
via the existing discharge point SWOOO, in order to permit. the operation of the new+ WwTP
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1 and cease discharge of untreated wastewater. _ - - I
Irish Water plan to construct and.make operational the proposed primary discharge point I . j
._. SWOOl once the legal issues are concluded. . . * 1 <
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' s ( b i ~ r O I r s a m Y h . C l u e ( i C h a b r i t l u i r r m ) , ' B n n J m u u l p k l . ~ ~ ~ ~ ~ ~ i Y U b l O d ) g C ~ ! ~ b r s d ~ T r a c h C o M 2 c l S r i . d ~ ~ ~ m s O a D I l , W l ~ I ~ n o U w , Z ~ T r a O r s m s l ~ 1.W1Hm I
b-p)n s ~ n a w J h d m a o r s n n ~ . ~ a d ~ s c a G c s m ~ r a h ~ a l a d r ~ ~ o c r r r s n y . p l e d Q ~ m . U m h l r c ~ ~ r w t e + ~ b a M l a : w t
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- Impact of the proposed chunge. . -.
wastewater discharge from the proposed WWTP primary *outfall. In ,2016 Irish Water
baseline for the Blackwater Estuary using the latest EPA monitoring data. '
(treatment + discharge via Dunnes Park outfall) were modelled for comparison. ~ - L '
i .. In 2009 UCC were commissioned to undertake modelling of the impact of the treated
commissioned UCC to review the existing model to examine a number of outfall scenarios.' The study included remodelling the existing scenario (no treatment) in order to provide a new
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In addition the following scenario (treatment + new outfall) and an interim scenario I
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, f Key findings: 0 The model shows the EQS values are achieved for Lower Blackwater Estuary for both
the interim and proposed final scenarios; 0 The model shows a significant improvement in E-& and Intestinal Enterococci
concentrations for both the interim and proposed final scenarios at Youghal, Claycastle and Redbarn Beaches;
0 The general conclusion of modelling exercise is that the interim discharge' yielas pollutant concentrations of a similar concentration to the proposed discharge loc with both interim and proposed discharge xenarios yielding significantly lo pollutant concentrations than the existing situation. 1 - .
At -I-- "- -4-- "- I__'-._I._AIL----L AI - -..- __.. .I-._.I A screening report for Appropriate Assessment was undertaken in relation to SWOOO t determined that a Stage 2 Appropriate Assessment is
The receiving waterbody, Lower Blackwater Estuary, is currently classified as achieving Modehe status under the Water Framework Directive. The current river Basin Manage Plan has set a target date of 2021 to achieve good status.
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I Requested Technical Amendment 1; 1
1; Irish Water requests that the following amendments are made to Schedule A, 8 and C to read as follows: 1 I +
I . I! 1; A.1 Primary Waste Water Dischaqe: (Applies to both S W d and SWl) L
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Note 1: Emission limit values shall apply until 31st December 2015 or until completion of the i
* proposed WWTP (whichever is soonef). 5 I 3 1... [
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Change to: . . Note 1: Emission limit values shall apply until construction of proposed. primary outfall ' . I i
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(SWOOl) a t 210852E, 078125N, or an alterative location as may be, agreed by the .
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A.2 Secondaty Waste W&er Dischatye: (Applies to both SW002 and SW003)
Change from: Note 1: Note 2:
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Discharge as secondary discharge shall cease on or before 31st December 2015. Emission limit values shall apply until 31st December 2015 or until completion of the proposed WWTP (whichever is sooner). 2 %
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Change to: - . .
Note 1: Note2:
Discharge as secondary discharge shall cease on or before 30th November 2017. Emission limit Values for SW002 and SW003 shall apply until operation of the' proposed WWTP.
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i A.3 Discharges to be discontinued:
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? I ' ! 1. discharge ,) Point Code Classification 2 ;
Location & Change in
swm Dunn's Park .--...,- - . -I _- - I--..._II_
Discharge to cease as Primary Discharge and to operate as a
t I - ' - swo . 1 jsw002 Paxe's lane
Discharge as a Secondary Discharge to cease and
discharge point to operate as
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Discharge to cease and
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Name of Receiving Water
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lower Blackwater - _"--I . ._ - .- - - . Estuary .
lower Blackwater Estuary
lower Blackwater - Gtuary
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Lower Blackwater Eituary
I ' . lower Blackwater
Estuary
~ Ducharge shall ceuse or change on
or before On construction and
commissioning of proposed primary
30/11/2017
-_ --- --- -_ - _ _
outfall,(SwOOl) .
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30/11/2017
.- 31/12/2019
30/11/2017
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. > Note 2: TO operate as a SWO on or before 31st December 2015.
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1 Note 1:
. -The monitoring requirements of this schedule shall only apply after 3lst December I
‘ I 2015 or upon completion of the proposed W P , whichever is the sooner.
(Propose to move the note to the “Primary Discharge Point Code: SWOOl) .
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C. 1 Improvement Programme for Primary Discha.pe
Proposed to omend os follows;
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New wastewater treatment plant 30/11/2017 Cease secondary discharqes in the aqqlomeration. As 14.3 above Upgrade of drainaqe network 31/12/2017. Installation of a new pumpinq station at Green Park 30/11/2017
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Please find enclosed:
1. Appropriate Assessment Screening f
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Environrne4bal Regulation Manager
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Report discharge point from Youghal WwTP Appropriate Assessment Screening for the relocation of a
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Contents
Introduction 3
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Leaislative Context
Methodology 5
Guidance Followed 5
Stages Involved in the Appropriate Assessment Process ' 6 1
Stage 1 : Screening I Test of Significance 7
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Brief Description of the Natura 2000 Sites 13
Potential Impacts of the Primary Discharge Relocation and Likely Significant Effects on Natura 2000 Sites 17
. * Screening
-, Background to the Project
Project Description
Description of the Receiving Environment and Monitoring Results
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Potential Impacts on Water Quality Potential Impacts on Qualifying Interests of the SAC and SPA Potential Cumulative Impacts with other Plans and Projects in the Area
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Summarv of Potential ImDacts and Likelv Sianificant Effects h 20
Likely Changes to the Natura 2000 Site(s) Elements of the Project where the Impacts are Likely to be Significant
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Screening Conclusions and Statement 23 I
Finding of No Significant Effects Report Matrix 24
Appendix A -Water Quality Modelling Results 26
2 I Irish Water AA Screening - Youghal
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Introduction This report provides an Appropriate Assessment (AA) Screening for the temporary relocation of the primary discharge point (SWOOI) for Youghal WwTP to an existing discharge point (SWOOO). The proposed relocation forms part of a proposed technical amendment to the existing discharge license for Youghal (D0139-01). It assesses whether the proposed relocation of the discharge point, which will discharge tertiary and UV treated water, is likely to have significant effects on a Natura 2000 Site(s) in view of best scientific knowledge and the conservation objectives of the site(s). Natura 2000 Sites are those identified as sites of European Community importance designated as Special Areas of Conservation under the Habitats Directive or as Special Protection Areas under the Birds Directive.
This report follows the guidance for AA published by the Environmental Protection Agency’s (EPA) ‘Note on Appropriate Assessments for the purposes of the Waste Water Discharge (Authorisation) Regulations, 2007 (S.I. No. 684 of 2007)’ (EPA, 2009); and takes account of the Department of the Environment, Heritage and Local Government’s guidelines ‘Appropriate Assessment of Plans and Projects in Ireland. Guidance for Planning Authorities’ (DoEHLG, 2009) and Circular L8/08 ‘Water Services Investment and Rural Water Programmes - Protection of Natural Heritage and National Monuments’ (DoEHLG, 2008).
This Screening for Appropriate Assessment was carried out by a qualified ecologist working for Irish Water.
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Legislative Context The Council Directive 92/43/EEC on the Conservation of Natural Habitats and of Wild Fauna and Flora, better known as “The Habitats Directive”, provides legal protection for habitats and species of European importance. Articles 3 to 9 provide the legislative means to protect habitats and species of Community interest through the establishment and conservation of an EU-wide network of sites known as Natura 2000. These are Special Areas of Conservation (SACS) designated under the Habitats Directive and Special Protection Areas (SPAS) designated under the Conservation of Wild Birds Directive (79/409/ECC) as codified by Directive 2009/147/EC.
Articles 6(3) and 6(4) of the Habitats Directive set out the decision-making tests for plans and projects likely to affect Natura 2000 sites (Annex 1 .I). Article 6(3) establishes the requirement for Appropriate Assessment (AA):
Any plan or project not directly connected with or necessary to the management of the [Natura 2000] site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, shall be subjected to appropriate assessment of its implications for the site in view of the site’s conservation objectives. In light of the conclusions of the assessment of the implications for the site and subject to the provisions of paragraph 4, the competent national authorities shall agree to the plan or project only after having ascertained that it will not adversely affect the integrity of the site concerned and, if appropriate, after having obtained the opinion of the general public.
3 I Irish Water AA Screening - Youghal
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Article 6(4) states:
I t in spite of a negative assessment of the implications for the [Natura 20001 site and in the absence of alternative solutions, a plan or project must nevertheless be carried out for imperative reasons of overriding public interest, including those of a social or economic nature, Member States shall take all compensatory measures necessary to ensure that the overall coherence of Natura 2000 is protected. It shall inform the Commission of the compensatory measures adopted.
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Methodology Guidance Followed Both EU and national guidance exists in relation to Member States fulfilling their requirements under the EU Habitats Directive, with particular reference to Article 6(3) and 6(4) of that Directive. The methodology followed in relation to this AA Screening has had regard to the following guidance: I
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Note on Appropriate Assessments for the purposes of the Waste Water Discharge (Authorisation) Regulations, 2007 (SI. No. 684 of 2007). Environmental Protection Agency, (EPA, 2009).
Appropriate Assessment of Plans and Projects in Ireland: Guidance for Planning Authorities. Department of Environment, Heritage and Local Government, (DoEHLG, 201 0).
Circular L8/08 -Water Services Investment and Rural Water Programmes - Protection of Natural Heritage and National Monuments. Department of Environment, Heritage and Local Government, (DoEHLG, 2008).
Communication from the Commission on the Precautionary Principle. Office for Official Publications of the European Communities, Luxembourg, (EC, 2000a).
Managing Natura 2000 Sites: the provisions of Article ,6 of the ‘Habitats’ Directive 92/43/EEC, Office for Official Publications of the European Communities, Luxembourg, (EC, 2000b).
Assessment of plans and projects significantly affecting Natura 2000 sites: Methodological guidance on the provisions of Articles 6(3) and (4) of the Habitats Directive 92/43/EEC. Office for Official Publications of the European communities, Brussels (EC, 2001).
Guidance document on Article 6(4) of the ‘Habitats Directive’ 92/43/EEC - Clarification of the concepts of: alternative solutions, imperative reasons of overriding public interest, compensatory measures, overall coherence, opinion of the Commission. Office for Official Publications of the European Communities, Luxembourg, (EC, 2007).
Nature and biodiversity cases: Ruling of the European Court of Justice. Office for Official Publications of the European Communities, Luxembourg (EC, 2006).
Marine Natura Impact Statements in Irish Special Areas of Conservation: A working document, National Parks and Wildlife Service, Dublin (NPWS, 2012).
European Communities (Birds and Natural Habitats) Regulations, 201 1 (S.I. No.477 of 201 1 ).
5 1 Irish Water AA Screening - Youghal
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Interpretation Manual of European Union Habitats. Version EUR 28. European * I ' Commission (EC, 2013). 1 .
Stages Involved in the Appropriate Assessment Process , '.
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Stage 1: Screening I Test of Significance This process identifies whether the WwTP discharge point relocation is directly connected to or necessary for the management of a Natura 2000 Site(s); and identifies whether the discharge point relocation is likely to have significant impacts upon a Natura 2000 Site(s) either alone or in combination with other projects or plans.
The output from this stage is a determination for each Natura 2000 Site(s) of not significant, significant, potentially significant, or uncertain effects. The latter three determinations will cause that site to be brought forward to Stage 2.' '
Stage 2: Appropriate Assessment This stage considers the impact of the WwTP discharge point ;elocation on the integrity of a Natura 2000 Site(s), either alone or in combination with other projects or plans, with respect to (1) the site's conservation objectives; and (2) the site's structure and function and its overall integrity. Additionally, where there are adverse impacts, an assessment of the potential mitigation of those impacts
The output from this stage is a Natura Impact Statement (NIS). This document must include sufficient information for the EPA to cany out the appropriate assessment. If the assessment is negative, i.e. adverse effects on the integrity of a site cannot be excluded, then the process must consider alternatives (Stage 3) or proceed to Stage 4.
Stage 3: Assessment of Alternatives This process examines alternative ways of achieving the objectives of the project or plan that avoid adverse impacts on the integrity of the Natura 2000 Site. This assessment may be carried out concurrently with Stage 2 in order to find the most appropriate solution. If no alternatives exist or all alternatives would result in negative impacts to the integrity of the Natura 2000 Sites then the process either moves to Stage 4 or the project is abandoned. '
Stage 4: Assessment Where Adverse Impacts Remain An assessment of compensatory measures where, in the light of an assessment of Imperative Reasons of Overriding Public Interest (IROPI), it is deemed that the project or plan should proceed.
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Stage 1 : Screening I Test of Significance In complying with the obligations under Article 6(3) and following the appropriate guidelines, this AA Screening has been structured as a stage by stage approach as follows:
Description of the project;
Identification of Natura 2000 sites potentially affected;
Identification and description of individual and cumulative impacts likely'to result;
Assessment of the likely significance of the effects'on the Natura 2000 site;
Exclusion of sites where it can be objectively concluded thatlhere will be no significant effects; and
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With regard to the Screening process the DoEHLG (2010) Guidance on Appropriate Assessment Screening states the following:
"The task of establishing whether the plan or project is likely to have an effect on a Natura 2000 : site or sites i s based on a preliminary'impact assessment using available.information and data, '
including that outlined above, and other available environmental information (e.g. water quality data), supplemented as necessary by local site information and ecological surveys. This is followed by a determination of whether there is a risk that the effects identified could be significant. "
If the effects identified are determined to be potentially significant, then the project is Screened in for a Stage'2 Appropriate Assessment.
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Screening Background to the Project
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Background information on the ongoing Youghal WwTP project is provided, followed by a description of the proposed discharge point relocation.
The Youghal WwTP Project The Youghal WwTP and network upgrade project is currently under construction. The WwTP was granted planning in 2001 by An Bord Pleanala (Atkins McCarthy, 2001 '). Further to planning approval a discharge licence was granted by the EPA in 201 2, and a foreshore licence for relevant works was granted in 201 3.
A site selection process identified the optimal location for the WwTP and the discharge point, and these locations were assessed for potential construction and operational impacts in the EIS submitted for planning, and in the reports submitted for the discharge and foreshore licence.
Selection of the Primary Discharge Point Two discharge points were initially considered - one within Youghal Estuary and a longer sea outfall outside of the estuary in Youghal Bay. Factors considered when selecting the preferred discharge point were UWWT standards, Bathing water quality (Youghal main beach and Claycastle outside of Youghal Estuary) and Shellfish water quality in Youghal Bay. The preferred option based on these considerations was an outfall within Youghal estuary (SWOOI ).
As described in Section 2.4.2 of the 2001 EIS, the discharge point selected was to be located in the vicinity of Ferry Point. The EIS noted:
"There is a large trench in the area of Ferry Point and extends for some distance down stream. This is likely to be as a result of the narrowing of the estuary due to the spit at Ferry Point. Discharging to this location would provide significant volumes of water to dilute the effluent, even at low tide, and due to increased currents at this location would provide good mixing and dispersion in the receiving waters. "
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A dye trace and drogue tracking study was conducted in the Blackwater estuary, which provided more detailed and up to date information on water current directions and velocity. Details of his survey are given in Appendix D of the EIS (Atkins, 2001). The report noted that dispersion and dilution characteristics in the estuary appeared to be good, with low concentrations of dye recorded before the dye reached the estuary mouth on the ebb releases and Youghal bridge on the flood releases.
Cork County Council carried out a CORMIX model to assess the bacteriological affects of a secondary treated discharge (at the proposed outfall location) on receiving water quality and found that bacteriological standards at relevant bathing and shellfish locations' could be met
' Atkins McCarthy (2001 ) Youhgal Main Drainage Scheme Environmental Impact Statement. Report prepared for Youghal Urban District Council. September 2001.
When the planning and licensing documents were prepared Youghal Bay (outside the estuary from Knockadoon to Knockavery) was not classified as a shellfish production area but a precautionary approach was taken as it had been a production area in the past. Currently in 2017, it is listed as a production area.
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(2001 EIS Appendix D). Updated bacteriological modelling was carried out in 2009, with . additional data used to generate a ‘worst case scenario’ of no wind, low river flows and maximum discharges from the WwTP. This model concluded that disinfection of the effluent would ensure Blue Flag water quality standards at beaches in proximity would be achieved for all river flow and effluent discharge, at all stages of the tide (AA Report dated November 201 1, Chapter 4. EPA Regulation 18 - Reply No. 3.).
Proposed level of treatment The 2001 EIS notes that secondary treatment with nutrient removal was required at Youghal in order to meet the requirements of the U W T Regulations 2001. The Blackwater Estuary downstream of Dromana Ferry, to near East Point, Youghal Harbour is designated as a “Sensitive Area” in Part 2 of the third schedule under the UWWT Regulations, 2001 and therefore nutrient reduction (Clauses 4(2)(a) and 4(3)) for one or both parameters (Nitrogen and . Phosphorus) is required.
’
In EPA Regulation 18 - Reply No. 1, Cork County Council stated under ‘Assessment of Impacts of Waste Water Discharges on Receiving Waters’ (Items 7 and 8 ) that, based on the level of treatment and the results of modelling of relevant substances for transitional waters, the discharge would comply with the European Communities (Surface Waters) Regulations 2009 (SI. No. 272 of 2009) and the mixing zone would be confined to the immediate vicinity of the discharge.
Appropriate Assessment submitted to the EPA for the Ferry Point Outfall The latest version (Nov 201 1 AA) states concludes:
Based upon the above assessments and adherence to the Effluent Quality Standards to be imposed on the operator it is not anticipated that the proposed development would negatively
I
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I impact on the conservation objectives of the Blackwater River SAC. I
There are no adverse impacts identified and no mitigation measures proposed that relate the treatmenvdischarge, with the level of treatment and dispersion/dilution available considered sufficient to avoid any negative impact.
I 1 l I 1 i;
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9 I Irish Water AA Screening - Youghal
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Project Description
The Project under consideration in this Appropriate Assessment Screening is the relocation of I
the primary discharge point from the proposed Ferry Point outfall (SWOOI) to Dunn's Park outfall (SWOOO). ' I
The Ferry Point oufall is currently listed as the primary discharge point in the Waste Water Discharge Licence for Youghal. While the WwTP is under construction, the construction of the outfall at Ferry Point (SWOOI), which was due to operate from 31/12/2015, has been delayed due to a legal case. In order to ensure that the WwTP can start operating once constructionds complete, it will be necessary to use one of the existing discharge points on an interim basis to- discharge the treated effluent. Due to the location of the network, the only option is to use the existing Dunns Park outfall (SWOOO) to discharge the treated effluent. Currently, untreated ,
effluent from the agglomeration is discharged primarily from the Dunn's Park and Paxes Lane (SW002) outfalls, with 60% through the former and 40% through the latter. It is anticipated that once the legal case is concluded, that the proposed Ferry Point discharge point will be constructed and used as the primary discharge point (for 100% of the treated effluent) as
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- . In order to inform this Screening for Appropriate Assessment, revised water quality modelling was undertaken to determine the implications for water quality of discharging 100% of the treated effluent from the Dunn's Park outfall relative to the existing scenario, and the proposed Ferry Point outfall (SWOOI in current licence). '
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10 I Irish Water AA Screening - Youghal
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Description of the Receiving Environment and Monitoring Results
BR230B
BR230S
BR230B
BR230BR
BR230S
EPA 2014 monitoring data is provided below. Station BR220 is located north of the existing Dunn's park outfall in the centre of the channel west of red bank. Station BR230 is located just south of the existing Paxes Lane outfall.
08/07/2014 34.05 115.5 1.5 2.5 4 3 0.025
08/07/2014 32.11 121.1 2 6 11.5 0.144
02/09/2014 34.03 92.4 0.5 14 1.8 0.121
02/09/2014 32.04 101.8 - 13 3.1 0.228
02/09/2014 32.87 94 0 5 13 1.6 0.188
BR230SR I 02/09/2014 I 27.32 I 111 I - I 11 2.9 0.555
volume surface and bottom. R= return- sample, second sample at same location per sampling visit. Note 2: Value for transitional waters. Note 3: Ortho-P compared to EQS limit value for Molybdate Reactive Phosphorus (MRP) for transitional'water body. Note that Orthophosphate measured on unfiltered samples may give a slightly higher reading than MRP. Linear interpolation to be used to establish limit value for water bodies between these salinity levels. Note 4: The Surface Water Regulations specify standards for Dissolved Inorganic Nitrogen (DIN) in seawater ( 3 4 . 5 ~ ~ ) as follows: Good status <0.25mg/l; and <2.6mg/I (Good status) for 0 psu salinity water, with linear interpolation between these salinity levels.
'
Additional monitoring data is available for 2015 for stations upstream and downstream of the discharges (Table 2.0). The upstream samples are taken from Youghal Bridge, while the downstream samples are taken near the Lifeboat station at the mouth of the estuary:
11 I Irish Water AA Screening - Youghal
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The data demonstrates that the water quality in the receiving water body is in compliance with Schedule 5 of the European Communities Environmental Objectives (Surface Water) Regulations 2009 (S.I. No. 272 of 2009) for relevant parameters..
With regard to Water Framework Directive (WFD) status, the Youghal estuary currently (201 0- 201 5) has Moderate ecological status overall, with Moderate 'biological status or potential' and High 'supporting chemistry conditions'. The requirement to restore Good status for this waterbody has been extended to 2021. The transitional waterbody of Youghal estuary, and the coastal waters of Youghal Bay are classed as Unpolluted by the EPA (2010-2012 Surface Water Quality ).
-
Phytoplankton growth in the estuary is limited by Phosphorus and light levels, with a potential '
shift towards Nitrogen limitation in the summer months when salinity increases (O'Boyle, 201 5).3 Ni Longphuirt et al (2015)4 identified that decreasing fertilizer application rates in the Blackwater catchment have resulted in reductions in Phosphorus concentrations in the Blackwater estuary, however Nitrogen concentrations have remained high due to the complex interaction between N and P load reductions and biochemical processes within the estuary.
O'Boyle, S; Wilkes, R; McDermott, G; Ni Longphuirt, S and C. Murray (2015) Factors affecting the accumulation of phytoplankton biomass in Irish estuaries and nearshore coastal waters: A conceptual model. Estuarine, Coastal and Shelf Science 155: 75-88 4 Ni Longphuirt, S; O'Boyle, S and DB Stengel (201 5) Environmental response of an lrish estuary to changing land management practices. Science of the Total Environment 521/522: 388-399.
12 I Irish Water AA Screening - Youghal
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Brief Description of the Natura 2000 Sites
This section of the screening process describes the Natura 2000 sites within a 15km radius of the original and proposed discharge locations. A 15km buffer zone has been chosen as a .precautionary measure, to ensure that all potentially affected Natura 2000 sites are included in the screening process, which is in line with Appropriate Assessment of Plans and Projects in Ireland - Guidance for Planning Authorities produced by the Department of the Environment, Heritage and Local Government.
Table 3.0 list the SACS that are within 15km of the WwTP discharge location, while Table 4.0 lists the SPAS, and Figure 1 .O shows their location in relation to the Youghal WwTP discharge locations. The qualifying interestskpecial conservation interests of each of the identified Natura 2000 Sites is also provided.
002i 70
000077
SAC'S located k
Blackwater River (CorkMlaterford) SAC
Ballymacoda (Clonpreist and Pillmore) SAC
hin 15krn of the Youghal WwTP
Estuaries 11 130)
Mudflats and sandflats not covered by seawater at low'tide [I 1401
Perennial vegetation of stony banks [ 12201
Salicornia and other annuals colonising mud and sand [I3101 . Atlantic salt meadows (Glauco- Puccinellietalia maritimae) [1330]
Mediterranean salt meadows (Juncetalia maritimi) [1410]
Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho-Batrachion vegetation [3260]
Old sessile oak woods with Ilex and Blechnum in the British Isles [91AO]
Alluvial forests with Alnus glutinosa and Fraxinus excelsior (Alno- Padion, Alnion incanae, Salicion albae) [91 EO]
Estuaries [1130]
Mudflats and sandflats not covered by seawater at low tide [1140]
Salicornia and other annuals colonising mud and sand [1310]
Atlantic salt meadows (Glauco- Puccinellietalia maritimae) [1330]
Mediterranean salt meadows
ischarae
Margaritifera margaritifera (Freshwater Pearl Mussel) [ 10291
Austropotamobius pallipes (White-clawed Crayfish) [lo921
Petromyzon marinus (Sea Lamprey) (10951
Lampetra planeri (Brook Lamprey) [lo961
Lampetra fluviatilis (River Lamprey) [lo991
Alosa fallax fallax (Twaite Shad) [I1031
Salmo salar (Salmon) [1106]
Lutra lutra (Otter) [1355]
Trichomanes speciosum (Killarney Fern) [I4211
13 I Irish Water AA Screening - Youghal
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Y
1 I European dry heaths [4030]
DO4028
004023
SPAS located WI
Blackwater Estuary SPA
Ballymacoda Bay SPA
rin 15km of the Youahal WwTP discharae
Wigeon (Anas penelope) [A0501
Golden Plover (fluvialis apricaria) [A1401 , ,
Lapwing ( Vanellus vanellus) [A1 421
Dunlin (Calidris alpha) [A1491
Black-tailed Godwit (Limosa limosa) [A1 561
'
Bar-tatled Godwit (Lrmosa lapponca) [A1 571
Curlew (Numenrus arquata) [A1 601
Redshank (Trmga totanus) [A1621
Wetland and Waterbirds [A9991
Wigeon (Anas penelope) [A0501
Teal (Anas crecca) [A0521
Ringed Plover ( Charadrws hlatrcula) [A1 371
Golden Plover (Pluv/aks apncana) [A1 401
Grey Plover (fluvialis squatarola) [A1411
Lapwing ( Vanellus vanellus) [A1 421
Sanderling (Calidris alba) [A1441
Dunlin (Calidris alpha) [A1491
Black-tailed Godwit (Limosa limosa) [A1 561
Bar-tailed Godwit (Limosa lapponica) [AI 571
Curlew (Numenius arquata) [A1 601
Redshank (Tringa totanus) [A1621 .
Turnstone (Areharia interpres) [A1 691
Black-headed Gull (Chroicocephalus ridibundus) [A1 791
Common Gull (Larus canus) [A1821
Lesser Black-backed Gull ( L a m fuscus) [A1 831
Wetland and Waterbirds [A9991
"
. . 14 I Irish Water AA Screening - Youghal
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3041 92
Ballycotton Bay SPA
Helvick Head to Ballyquin
SPA
Ringed Plover (Charadrius hiaticula) [A1 371
Golden Plover (Pluvialis apricaria) [A1 401
Grey Plover (Pluvialis sguatarola) [A1 411
Lapwing (Vanellus vanellus) [A1421
Black-tailed Godwit (Limosa limosa) [A1 561
Bar-tailed Godwit (Limosa lapponica) [AI 571
Curlew (Numenius arquata) [A1 601
Turnstone (Arenaria interpres) [AI 691
Common Gull (Larus canus) [A1821
Lesser Black-backed Gull (Larus fuscus) [A1 831
Wetland and Waterbirds [A9991
Cormorant (Phalacrocorax carbo) [A01 71
Peregrine (Falco peregrinus) [A1 031
Herring Gull (Larus argentatus) [A1 841
Kittiwake (Rissa tridactyla) [A1881
Chough (Pyrrhocorax pyrrhocorax) [A3461
15 I Irish Water AA Screening - Youghal
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Potential Impacts of the Primary Discharge Relocation and Likely Significant Effects on Natura 2000 Sites
The purpose of this section of the screening is to examine the possibility that the proposed primary discharge relocation to an existing discharge point, either individually or in combination with other plans and projects, may result in significant negative effects on the Conservation Objectives and the integrity of the Natura 2000 Sites identified.
The most apparent potential risk to a Natura 2000 Site(s) from a WwTP discharge is to the water quality of the receiving environment, and the assessment therefore needs to consider whether the receiving environments water quality has the potential to interact with the qualifying interests of the Natura 2000 Sites identified. Using the source-pathway-receptor model, only the qualifying interests and special conservation interests of the Blackwater River (CorWaterford) SAC and Blackwater Estuary SPA were considered to have potential connectivity to Dunn's Park discharge point. Sites at a further distance are not considered further in this assessment as they were either unconnected, or they are at a sufficient distance such that significant dilutionldispersion is considered available in intervening coastal waters.
The Conservation Objectives of these relevant sites were reviewed as part of this Screening Assessment: , NPWS (2012) Conservation Objectives: Blackwater River (CorWaterford) SAC
. I 3
I
002170. Version 1 .O. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht. NPWS (2012) Conservation Objectives: Blackwater Estuary SPA 004028. Version 1 .O. ., National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht.
The relocation of the discharge point is not directly connected with or necessary to the,
management of the site for nature conservation. . , , . .
Potential Impacts ,on Water Quality 1 . .
Revised water quality monitoring was undertaken using Mike21 Software (Results provided in Appendix A). This included the remodelling of the existing scenario (no treatment) to provide a new baseline using the latest EPA monitoring data to provide inputs to the Blackwater Estuary. The proposed scenario (treatment + new outfall SWOOI) and an interim scenario (treatment + discharge via Dunnes Park outfall SWOOO) were modelled for comparison.
The three scenarios modelled are outlined below: Scenario 1: The Existing 2017 scenario - inputs to this model were based on latest available municipal and catchment load figures. Untreated wastewater discharged from Dunnes Park outfall(SWOO0) and Paxes Lane outfall (SW002).
Scenario 2: The Proposed Outfall scenario - Future loads discharged from the new WWTP via the proposed outfall at.Fenypoint (SWOOI ). Treated wastewater.
Scenario 3: Interim Option 1 (Dunnes Park) - Loads discharged from the new WWTP via the existing outfall at Dunnes Park (SWOOO). Treated wastewater.
17 I Irish Water AA Screening - Youghal
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I' I , .. ,
.*. The key findings were as follows:
The model shows Suface Water Regulation EQS values are achieved for Lower Blackwater Estuary for both interim and proposed scenarios. The model shows dramatic improvement in E-Coli and Intestinal Enterococci '
concentrations to excellent standard for both interim and proposed scenarios at Youghal, Claycastle and Redbarn Beaches The general conclusion of modelling exercise is that the interim discharge yields pollutant concentrations of a similar order of magnitude as the proposed discharge location with both interim and proposed discharge scenarios yielding significantly lower pollutant concentrations than the existing situation.
Potential Impacts on Qualifying Interests of the SAC and SPA
The existing untreated discharge (SWOOO) has not had obse&able adverse effects on the . '
nearest designated habitats - 'Mudflats'and sandflats' and 'Estuaries'. The habitats were surveyed as part of the EIS studies in 2001, and resurveyed in 2010 as part of NPWS conservation assessment surveys5. The area around Dunn's Park outfall comprises 'sand and mixed sediment with polychaetes and crustaceans community complex' extending into 'sand and mixed sediment with polychaetes and crustaceans community complex'. These are typical- estuarine habitats and found throughout the estuary. Neither benthic study identified any specific habitat biotope'or signs of habitat deterioration in the vicinity of any of the outfalls from the existing untreated discharges. It is also important to note that Mudflats and sandflats and Estuaries are currently at Favourable conservation status in the SAC.
The Annex II species that move through the estuary are salmon, river lamprey, sea lamprey and twaite shad. The relocation of a'treated discharge point does not have the potential to impact. these species as the relocation will result in no deterioration in water quality. There 'are records of otter from the estuary (NBDC website) where they are likely to forage in intertidal habitats. As water quality will not be affected, there is no potential for the relocation of the discharge point to impact otter either directly, or indirectly due to reduced food sources. The estuary is also designated as an SPA for a range of wetland bird spcies; chiefly waders, and the wetlands that ' support them. As water quality will not be affected by the discharge relocation, there is no . '
potential to impact on the wintering bird species for which the SPA is designated, either directly, or indirectly due to reduced or altered food sources. '
It is noted that the Natura 2000 data form for the SAC identifies the key high pressures as fertilisation, movinglcutting grass and grazing. 'Discharges - Disposal of household and recreational waste' is listed as a low threavpressure, which is likely to refer to the current untreated discharges.
The relevant habitats have maintained favourable conservation status despite untreated waste being discharged into the estuary. The current proposal, which involves the use of one of the current outfalls to discharge highly-treated effluent, is therefore considered to have no potential
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NPWS (201 2) Blackwater River (CorkNVaterford) Site Code 21 70. Conservation objectives supporting document -marine habitats. Version 1. January 2012.
18 I Irish Water AA Screening - Youghal
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.. ,
to result in adverse effects to the conservation status of these habitats. While it is acknowledged that the optimal discharge point is the proposed discharge point at Ferry Point (SWOOlj, it has been demonstrated through updated modelling that discharging the treated effluent at Dunn's Park outfall (SWOOO) will not cause any deterioration in water quality in the estuary relative to the proposed discharge point. This further strengthens the conclusion that the conservation objectives of the relevant habitats will be maintained. '. . ,
Considering the objective information provided above, it is concluded. that the discharge is not likely to significantly affect the qualifying interests of the River Blackwater (CorkMlaterford) SAC or the Blackwater Estuary SPA.
In accordance with the Waste Water Discharge (Authorisation) Regulations 2007 (S.I. No. 684 of 2007) the relocation of the Youghal WwTP discharge point does not have the potential to impact the relevant qualifying interests identified, and therefore will not affect the conservation objectives of the River Blackwater (CorWaterford) SAC or the Blackwater Estuary SPA. No significant adverse impacts on any Annex I habitat, Annex I I species, or Annex I Bird Species are anticipated as a result of the discharge point relocation.
* -
No significant adverse impacts on the qualifying interests of the remaining Natura 2000 Sites identified within 15km of the discharge point is considered likely due to lack of hydrological connection between the discharge point and the relevant terrestrial SACs and SPAS, or the dilution and dispersion provided by intervening coastal waters for remote coastallmarine SACs and SPA sites.
Potential Cumulative Impacts with other Plans and Projects in the Area
As part of Stage 1 Screening, in addition to the discharge point relocation, other relevant projects and plans in the relevant region must also be considered. This step aims to identify at this early stage any possible significant effects on the Natura 2000 Sites from the discharge point relocation in-combination or cumulative with other plans and projects. Existing plans which have been examined include:
Cork County Development Plan 2015-2021 Youghal Town Development Plan - Youghal Town Council 2009-2014 Blackwater Estuary Water Management Unit Action Plan' County Cork Biodiversity Action Plan 2009-2014
The above plans have been assessed in accordance with Article 6(3) of the Habitats Directive and Part XAB of the Planning and Development Act, 2000, and are not envisaged to result in significant effects on the integrity of the Natura 2000 network. A possible future marina development is identified in the Youghal Town Development Plan, but any such development would be subject to Appropriate Assessment.
19 I Irish Water AA Screening - Youghal
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The water quality modelling has taken full account of upstream water quality pressures in 1.
determining the predicted water quality in the estuary.
A search of Planning Applications on the Cork County Council Planning Website was undertaken for any significant developments with the potential to contribute to in-combination effects with the. discharge point relocation in the Blackwater Estuary area. Numerous minor residential and commercial development have been granted or are seeking planning permission in the town, however due to their scale or location no projects with the potential to contribute to in- combination effects with the discharge point relocation were identified.
I I .
, . . .
Summary of Potential Impacts and Likely Significant Effects Table 6.0 provides a summary of the likely significant impact of the relocated discharge point on the conservation objectives of the Natura 2000 sites potentially linked to the relocated discharge points identified in Tables 4.0 and 5.0.
I . , . . ~
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Table 6.0: Potential Significant Impacts on Natura 2000 sites from the relocation of the Youghal WWTP primary discharge‘point
Blackwater River No impact on
(CorkMlaterford) SAC interest qualifying
Ballymacoda (Clonpreist No impact On
and Pillmore) SAC interest Ardmore Head SAC No impact on
qualifying interest No impact On
qualifying interest No impact On qualifying interest No impact on qualifying interest No impact On qualifying
qualifying
Blackwater Estuary SPA
Ballymacoda Bay SPA
Ballycotton Bay SPA
Helvick Head to Ballyquin
SPA interest
21
~
Irish Water AA Screening - Youghal
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
interest I qualifying interest interest I No impact on qualifying No impact on No impact on qualifying interest qualifying interest interest
No impact on qualifying No impact on No impact on qualifying interest qualifying interest interest
No impact on qualifying No impact on No impact on qualifying interest
No impact on qualifying No impact on No impact on qualifying interest qualifying interest interest
No impact on qualifying No impact on No impact on qualifying interest qualifying interest interest
No impact on qualifying No impact on No impact on qualifying interest qualifying interest interest
qualifying interest interest
No impact on No impact on qualifying qualifying interest interest
‘No impact on No impact on qualifying qualifying interest interest
No impact on No impact on qualifying qualifying interest interest
No impact on No impact on qualifying qualifying interest interest
I
No impact on No impact on qualifying qualifying interest interest
No impact on No impact on qualifying qualifying interest interest
I
No impact on No impact on qualifying qualifying interest interest
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' i Likely Changes to the Natura 2000 Site(s) The likely changes that will arise from the relocation of the discharge point have been examined in the context of a number of factors that could potentially affect the integrity of the identified Natura 2000 Sites. Overall, it has been found that the current waste water discharge will not affect the integrity of the identified Natura 2000 Sites.
i j i '
Elements of the Project where the Impacts are Likely to be Significant No elements of the proposed discharge point relocation are likely to cause significant impacts on NATURA 2000 Sites. I1
{
I
22 I Irish Water AA Screening - Youghal
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Screening Conclusions and Statement The likely impacts that will arise from the proposed discharge point relocation have been examined in the context of a number of factors that could potentially affect the integrity of the Natura 2000 network. None of the sites within 15km of the discharge location will be adversely affected. A finding of No Significant Effects Matrix has been completed and is presented in next section of this Screening Statement.
On the basis of the findings of this Screening for Appropriate Assessment of Natura 2000 Sites, it is concluded that the proposed temporary relocation of the primary discharge point for Youghal WwTP will not have a significant effect on the Natura 2000 network, alone or in-combination with other plans and projects, and a Stage 2 Appropriate Assessment is not required. _.
23 I Irish Water AA Screening - Youghal
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Finding of No Significant Effects Report Matrix
$J .- Name and location of. Natura 2000 site
Description of the project or plan
Is the project or plan directly connected with or necessary to the management of the site?
Are there other projects or plans that together with the project or plan being assessed could affect the site?
Describe how the project or plan (alone or in combination) is likely to affect the European Site(s).
Explain why these effects are not considered significant.
List of agencies consulted: provide contact name and telephone or e-mail add res .
Response to consultation.
Who carried out the assessment?
24 I Irish Water AA Screening - Youghal
. .
Blackwater River (CorWaterford) SAC; Blackwater
Relocation of primary discharge point for Youghal WwTP from the proposed Ferry point outfall SWOOl (as indentified in current licence) to the interim Dunns Park outfall SWOOO (current discharge point)
I
Estuary SPA . .
NO. '
No.
As Dunn's Park outfall is directly connected to the River Blackwater SAC and Blackwater Estuary SPA, the potential impacts of discharging treated effluent from this location, relative to the proposed Ferry Point outfall, need to be considered. Water quality monitoring has demonstrated that there will be no deterioration in water quality due to the discharge of treated effluent from Dunns Park outfall relative to the proposed Ferry Point outfall, and that both these scenarios improve water quality relative to the current discharge of untreated waste from Dunns Park and Paxes Lane outfalls.
The relevant habitats have maintained favourable conservation status despite untreated waste being discharged into the estuary. The current proposal, which involves the use of one of the current outfalls to discharge highly-treated waste, is therefore considered to have no potential to result in adverse effects to the conservation status of these habitats.
Due to the lack of impact on water quality and estuarine habitats, no impact is predicted for any aquatic Annex II species of the special conservation interests of the SPA. N/A
NIA
Qualified Ecologist, Irish Water
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Sources of data
Level of assessment completed
Where can the full results of the assessment be accessed and viewed?
Overall Conclusion
NPWS database; EPA database; WFD Ireland database; and Information from Irish Water.
Desktop and Field walkover survey
EPA
Stage 1 Screening indicates that the relocation of the Youghal WwTP discharge will not have a significant negative impact on the Natura 2000 network. Therefore, a Stage 2 'Appropriate Assessment' under Article 6(3) of the Habitats Directive 92/43/EEC is not required.
25 I Irish Water AA Screening - Youghal
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Appendix A = Water Quality Modelling Results
26 I Irish Water AA Screening - Youghal
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Simulation values ,u&l midge Dunner Park U/S Dunnes Park D/S Paxer Lane UfS P a m Lane D/S New Outfall UlS New Wall DIS YvoDhrl Be& Claynstlc Be& Redbun Be& Lower ENuly
a 9 m m n 8.453676521 a406393102 a290962875 a285634132 a402257593 a 2 7 6 9 m n 8.165350968 a m i 6 8 1 9 7.826212038 9.036269091 7 . ~ ~ 1 6 9 9 7.720677915 7.704847496 7.674656784 7.678195552 7.705939842 7 . ~ 3 3 2 0 8 7 7.0~179498 7 . m a 1 m 7.~0130915 a415161903
99.57% 1 m . m 1m.m 1m.gm 105.05% 1 m . m 105.~1% 1ffi.m iff i .9m 112.8996 104.7% 15.64667402 14.59692433 14.4998374 14.29922624 14.29419129 14.4920642 14.33881998 14.2mDu146 14.13179039 U.9uo6944 15.21022176 o.-s i O.mEn7%24 0.008533241 o . rn7~54c8 o .mi32086 0.008528815 o . m m 1 2 0.008545918 0.m8368242 0.m5885712 0.013196242 0.021385937 0.015584477 0.01468247 0.012970978 0.012961922 0.014634769 0.013587678 0.012499292 0.011975808 0.011079906 0.185626217 0.072271991 0.074015297 0.07ana7 0.070734023 0.074754728 0.078314832 0 . 0 6 7 9 ~ ~ ~ 0 . 0 7 3 2 ~ 0.0696262 o . w g m 3 6 0.092113811 0.05591298 - 0.057023629 0.059326018 0,05298425 0.055693435 0.059167369 0.051509031 0.052353302 - 0 . m 9 1 0 5 5 0.029381574 0.143947124
0.m4027334 o . r n w s a 0.0339mi4 o.ancmm 0.001~8608 o . m m m 1 0 . 0 0 4 0 0 ~ ~ 9 0.001301908 .0.00132%2 0.003~cas7 0.m6449138 0.008797868 0.006759363 0.036771691 O.CC6297797 0.006458104 0.036737125 0.03653yL86 0.036432157 0.0063205(33 O.CO37875 O.CC9C62356 im7.74163 ~720.10226 13909.51913 1 1 4 7 9 . ~ ~ 12437.68669 u m o . s m 12y)3.66513 13100.36562 ~703.91852 6 9 5 0 . ~ ~ 7 2 5984.936297 ion.292022 i i 4 6 . m m 1z69.184158 10~0.264741 1133.957924 1266.113357 1140.846697 1 1 9 9 . 7 0 ~ ~ 1161.442975 611.6964124 5425621471
0.73109998 0.070757624 0.074(~14333 0.064759728 0.06im7609 0.0736815~ 0.062492337 0.072615208 0.070971901 0.05262m2 0.091116841
71.417 4am 104.855 54.307 85.743 106.659 94.374 96.926 60.036 0.051 2 a 3 u 324.413 2 3 s . m 520.80) : 251.010 412.609 502.033 443.028 496.257 353.973 0.572 125.852 3.799548361 3.2368)2268 3.1674508 2.988811161 2.990584522 3.158094446 3.021210218 2.901108565 2.836561618 2.622815402 4.61- O.CC0447654 0.000387997 0.000373119 0.e336938 O.mo336611 0.000372414 0.000348158 0.000330363 0.000318391 0.000299657 o.miaw906 0 . 0 0 3 0 3 ~ 2 ~ o.rn299o881 o.mmm38 o . m m n i 0 . m 5 6 3 o.mmfi54 o.rnm6919 0.- o.myKw o.mmse-521 O.CO.3719875 0.031697688 0.024140776 0.023MOM8 0.02oTr2137 0.021016026 0.023474974 0,021927402 0.021748285 0.020815231 0.0173(35717 0.200622274 2o .mm.m 25.9~3~7547 26.60065718 28.0-m2658 2 a 0 5 y ~ m 26.68088447 2 7 . ~ ~ 7 6 2 2anrn3484 29.2213092 m.y)466519 11.56547225,
0.01m52409
1810l.y)861 1646059757
o . m m m
159.232 707.412 6.805656484 O.mO618681 0.000309163 0.076751716 19.75375818
0 01M29252 0008594006 19ooo89995 1729 753712
m m 674 862
4 933970609 0 o(30566418
0 000285409 0 051200269 25 10922873
0.010855421
2 m i z 3 m O.a)8ta8907
1838211758 201.416
4.686111885 O.mo544854 0.000237008 0.M8541168
943.407
2 5 . m 3 m 5
0.011158848 O.CO8745763 16790.88898 1535.821185 153.910 691.998 4.151652347 0.000506275 0.000196914 0.041618747 27.25512416
0.011284795 0.008880756
17942.3115 1649.385817 191.353 903834 4.123865198
O.oaKarJ1 O.mo202258 O.MWC032 27.34385993
0.010862062 0.m8824315 m . 3 4 3 7 2
1.83Et03 198143 917.364 4.656439883 O.aay13279 0.000234(305 0.048096136 25.8ES10005
0,011132392 O . m g M 5 2 3 18160.92381
1.67Eto3 182,181 808.642 4.288362969 0.000521074 0.00021269
o.m.4832895 i6.88902157
0.011589617 a m - 0 3 1.85Etoo
1708161065
1094.809 3.828869175 O.mO499887 0.000208977 0.640331487
233.776
27.95476445
0.01173193s 0.m8853981
1.77Etoo 1.63Eto3
240.819 1126.179 3.639226906 O.mO494893 0.000226188 0.038992076 2 a 4 ~ 2 0 6 8 ?
0.011211363 7.95E-03 9.11E43
8 0 6 . m 8 6 41.021 192.696 3,129088974 0.00465595 0.000209821 0.033175791
0.0110519
48.243
0 . 4 M W 10.81l3Bl
21 I Irish Water AAScreening - Ywghal
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Scenario 2 Proposed Summary
15.04713805 14.59745772 1 4 . W 3 7 5 14.29981671 14.29QS1472 14.49266195 14.3394023 14.2007?&37 14.l3256226 13.92391826 0.002469569 0.~2279862 o.rn22447~ 0.032175898 0.002194074 o.rn2240171 0.002195473 0.002163027 0.~02115336 o.mm7635 0.015ia1648 0.0101~875 0.009568661 0.m8669126 0.008566502 0.009552899 0.m8939258 0 . m 3 6 3 9 o . m m i % 0.006621728
. 0.024028236 0.019847785 0.020328197 0.019693733 0.019987873 O.Om24824 0.019378022 0.019308633 0.018814441 0.017323%1 0.028445114 O.OlTM084 0.017166739 0.01529l386 0.015547991 0 . 0 1 ~ 1 8 2 0.014659351 0.013270618 0.011825427 0.00715737 0.028226676 0.02608406 0.026342436 0.022243952 0.021827873 0.026279725 0.020764748 0.026214755 0.025806913 0.023311174
1.307125545 1.455550402 1.42210511 1.243797167 1.302594568 1.411034251 1.275851381 1.21Etm 1.108189122 0.55yu245 0.388571178 0.271936 0.25493901 O.MOL3l322 0.2C6555l54 0.25126ypDI 0.21038?858 0.174034639 0.l503055W 0.069404373
0.039 0.034 ' 0.039 3.~5429727 3 . 0 8 0 7 8 1 ~ ~ 3.012315102 2 .~~163985 2~~0~6325 3 . ~ ~ 9 7 3 2 2.879430366 2 . 7 6 0 2 ~ ~ ~ 5 2 . m i m 2.515885413
0.002544458 0 . ~ 2 5 1 6 ~ 2 0.~02558539 0.002626456 0.m2635152 0.002560253 o.rn615957 0 .~267112 0.002690675 0.m2739814 0.030213l37 0.030168101 0.0301641 0.030158486 003015918 0.030163842 0.030159792 0.030155823 0.030152933 0.030140406
6.95865049 107.61% 143.9996
10.39784039
0.055848328 0.021253653
0.029235593 0.005131037
o.rn31n68
0.02540837 . .
o .rn74mi i
o.rnsmw.5 2.029292413
0.017 0.W 6.632047062 0.030369485 0.030230835 0.059366742 19.1po918516
6.466341854 116.88)( 149.44%
10.38108995 0.003134733
0.021900849 0.017982575 o.oFx)48855
0.036326875 2184706254 0.41l20l268 0.m 0.0%
0.030- O.CC0204353 0.037034551 25.14082064
0.033noyu
0.005502702
4.756698293
6.304057367 117.94% 153.23%
0.0032W557 0.031453436 0.022543576 0.017836555 0.029465334
0.- 2.121382318 0.382598038
io.3nss122
o.esmsss
0.021 0. 108
4.510651297 0.030301839
0.034859669 25.83691729
0.@184984
~.0823mi42 121.75% W.85%
10.36129355 0.003229384 0.02619M39 O.OUM7W 0.015903462 0.029382017 0.037093181 0.m6114391 1.a33422B1 OX6334359 0.017 0 . m
3.996326611 0.030299614 0.030161425 o . o a m i o m 27.28191411
6.11008a66 121.92% l56.m
10.35989482
0.025652104 0.023828428
0.028821889
0.036732457 1.891161433 0.M9924815
0 . 0 0 3 2 ~ n
o.oim24912
0 . m 7 i ~ s m
0.019 0.091
3.965117734 0.0303C07M 0.030167088 0.0 29 235353 27.36926533
6.299601203 11a489( 153.34%
10,37727607 0.003208616 0.031023591 0.022551837
0.029383568 0.m6035382 0.m6466853
3.7%-01
0.017785715
2.108913266
0.021 0.103
4.481486984 O.COXO1611 0.030183036 0.034455099 25.91924739
6.153019823 122.m 155.05%
10.36617954
0,028254936 0.023041Ea4 0.015823345 0.027850105 O.Oo6588506 0.03657115
1.%3755 3.23E-01
o.rn32004~
0.016 0.078
4.125814003 O.ooo298446
0.031700405 27.36926533
o.moim1yI
6.133181813 127.41% 151.57%
10.3s291691 0.W326314 0.023925€43 0.023368118 0.014028234
0 . m 7 y m l s 0.0335592%
6.W-03 1.76Etm
0.26825444 0.017 0.079
3 .67030~2 0.030296682 0.030172964 0,027629953 28.M589526
6.151321637 133.236 154.11%
10.362EV449 0.002947957 0.023818185 0.018790362
0.02sm%5a 0.036381645 0.005561785
1.63Etm 2.m-01
0.012172039
o.ol2 0.051
3.578158031 0.030276738 o.mopo7591 0.027147561 2871994402
5.946544443 148.9% =41%
10.3353162 0.00309556( 0.019884027 0.021623829 0.010737451 0.028666ms 0.0077-3
6.2E-03 7 , s - 0 1
0.144473733 0.W
3.01188495 0.030282644 0.030170844 0.023263518 30.04021057
0.011
. . . ^. . . . . I. . ,
. .
28 I Irish Water AA Screening ~ Ywghal
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